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TP Minds Australia
October 2024



With the OECD’s Base Erosion and Profit Shifting (BEPS) project continuing to gain momentum around the globe, the level of action and convergence being taken by individual countries and governments has never been seen before. The pace of change makes it challenging to stay abreast of local requirements and their impact on current and future transfer pricing structures and policies for multinationals of all sizes.

Closer to home, the Australian Taxation Office wins against Chevron Australia in 2017 on the pricing of cross-border intragroup funding. This, along with the most recent win against Singtel in 2021, arguably represents the most significant transfer pricing decisions in Australian history. Moreover, the most recent Glencore taxpayer win has established an important precedent that may have a ripple effect across industries and methodology selected for pricing of cross-border related party transactions.

BDO’s Global Transfer Pricing Practice helps groups navigate this fast changing transfer pricing environment. BDO’s international network spans across the globe. Aided by dedicated transfer pricing practitioners in Australia and across our international network, we provide a range of services covering the transfer pricing life cycle - compliance, planning, audit defense, benchmarking – as well as technology solutions to manage growing complexity and efficiency needs. BDO works with companies to develop bespoke transfer pricing structures and policies that are fit for purpose, defensible, flexible and in line with commercial operations. Our aim is to alleviate some of the complexities involved in staying on top of the current transfer pricing changes and reduce the level of uncertainty faced by our clients today and into the future.